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Federal AviationAdministrationFAA Perspective
and Regulatory
Update
on Aircraft RFID
Applications
IATA 2nd RFID & Paperless Technical
Operations Conference
November 17, 2015
Brian Verna
Federal Aviation Administration
Avionics Maintenance Branch (AFS-360)
2Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
Presentation Topics
• Current Policy
• Examples of RFIDs and their Operational
Uses
• Certification of Installed RFID Devices
• Operational Allowance Considerations
• Conclusion
3Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
Current Policy (1 of 2)
• FAA AC 20-162, “Airworthiness Approval and
Operational Allowance of RFID Systems”
– Information, guidance, and methods for an acceptable way to
use RFID devices, readers or interrogators installed on
aircraft
• FAA AC 91.21-1C, “Use of Portable Electronic Devices
Aboard Aircraft”, dated May 7, 2015
– Use of “portable” RFID devices on baggage, mail containers,
cargo devices and galley/service carts
– Guidance on design (e.g., RF emissions, transmission
function, and battery qualification)
4Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• Draft AC 20-162A expected to be published for
public comment Dec. 2015
– Limits scope to installed, passive RFID devices only
– Active and battery assisted passive RFID tags addressed
in AC 91.21-1C and future AC
– RFID operational considerations removed from AC 20-
162 and addressed in new AC
– Incorporates SAE Aerospace Standard (AS) 5678A for
functional and environmental qualification requirements.
Current Policy (2 of 2)
5Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
13.56 MHz 915 MHz 2.45 GHz
Passive RFID Tag Examples
Active RFID Tag Examples
6Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
Air Data Inertial
Reference UnitSmoke Detector
7Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
Examples of Operational Uses
8Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• Airworthiness concerns about RFID devices installed on aircraft include—
– Integrity, accuracy, and authenticity of both safety-related
and identification data from RFID devices
– Fire and electrical safety, crashworthiness, and
environmental effects
– RFID device-generated RF intended transmissions or
spurious emissions, both of which can interfere with
aircraft electrical and electronic systems and components
– Maintenance required for RFID devices and readers.
Certification of Installed RFIDs (1 of 6)
9Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• Performance
– Meet the performance standards in SAE AS5678A
– Meet the requirements of ATA Spec 2000
• Configuration control
– Document RFID device(s) make, model, and part number
in the product or equipment Instructions for Continued
Airworthiness (ICA)
– Specify how the device is mounted, located, oriented and
used where configuration control is required.
Certification of Installed RFIDs (2 of 6)
10Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• Software and complex hardware
– If the application uses software, determine software level per
AC 20-115C and RTCA/DO-178B
– If the application uses complex electronic hardware, determine
hardware level per AC 20-152 and RTCA/DO-254
• Environmental qualification
– Follow SAE AS 5678A, Section 6.3.5, for other environmental
qualifications of RFID devices.
Certification of Installed RFIDs (3 of 6)
11Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• Flammability and fire safety.
– RFID device itself, must meet the flammability
requirements
• Larger tags - meet of 14 CFR § 25.853(a) and
appendix F, part I(a)(1)(ii)
• Smaller tags - meet of 14 CFR § 25.853(a) and
appendix F, part I(a)(1)(v)
– Flammability consideration must consider also the
means of attachment to the article.
Certification of Installed RFIDs (4 of 6)
12Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• Mounting and attachment integrity
– The RFID installation must be permanent.
– Installation of RFID devices must comply with 14 CFR
certification requirements.
• ICA
– State service life limit
– State if and when the RFID device requires battery
replacement, recharging, or other periodic maintenance.
– State whether the RFID device, if malfunctioning, must be
removed from the aircraft and replaced with one of the
same type and configuration.
Certification of Installed RFIDs (5 of 6)
13Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• Installed on a non-interference basis.
– Comply with 2X.1301 – Must perform its intended
function.
– Comply with 2X.1309 – Must not impact the
operation of required equipment.
• Alterations per 14 CFR 43.13(b)
– Installer must ensure that “ ...the condition of the
aircraft, airframe, aircraft engine, propeller, or
appliance worked on will be at least equal to its
original or properly altered condition…”
Certification of Installed RFIDs (6 of 6)
14Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
Operational Allowance of RFIDs (1 of 4)
• Installation of RFID tags has lead to
innovative uses to take credit for required
maintenance and inspection actions.
• This changes installation from “non-
interference” only to performing required
functions.
• As such, additional requirements must be
applied when considering RFID tags for
these functions.
15Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• Use of RFIDs to convey information
required for maintenance programs share
many of the same considerations of any
electronic record keeping system.
• AC120-78 outlines many of the basic
requirements.
– Uniqueness
– Reliability
– Security
– Traceability
Operational Allowance of RFIDs (2 of 4)
16Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• Each RFID tag must retain information and
possess the same qualities as the printed
identification tag.
– Identify a specific part including the basic
information necessary to identify individual parts.
– Information must be permanently retained.
– Information must be difficult to alter or change.
• To accomplish this, the tag’s basic
information must be locked.
Operational Allowance of RFIDs (3 of 4)
Uniqueness and Reliability
17Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
• As a system, the RFID program being used
must be evaluated for security vulnerabilities.
– Must include the tags, readers and the back-end
support systems.
– Use a risk based approach to identify risks and
necessary mitigations.
– Restrict unauthorized alteration of a record, record
entry, or document.
– Readily identify person doing initial data entry or
making changes to data
Operational Allowance of RFIDs (4 of 4)
Security and Traceability
18Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
Conclusion…
• RFID systems have the potential to provide great innovations on data collection.
• RFID systems must provide equal or better information integrity as the program requirements it replaces.
• RFID systems must be dependable and complete to readily allow airworthiness determinations.
• We are working to develop policy and guidance to ensure continued operational safety.
19Federal AviationAdministration
IATA 2nd RFID & Paperless Technical Operations Conference
November 17, 2015
Contact Information
Address: FAA Flight Standards Service
Brian Verna
Aerospace Engineer, AFS-360
Avionics Maintenance Branch
950 L’Enfant Plaza S.W.
5th floor, suite 5100
Washington, DC 20024
Phone: (202) 267-1710
E-mail: [email protected]